CMS Issues CY 2024 Proposed Rules for Medicare Physician Fee Schedule (MPFS)

On July 13, 2023, the Centers for Medicare and Medicaid Services (CMS) issued the proposed rule for the Medicare Physician Fee Schedule (MFPS). These proposed rules cover physician services furnished to beneficiaries on or after January 1, 2024. Highlights are described below:

  • CMS proposed Conversion Factor (CF) of $32.7476, which includes a budget neutrality factor of -2.17 percent, and a one-time 1.25 percent increase provided by the Consolidated Appropriations Act, 2023 (CAA 2023).
  • Based on the proposed changes for the RVUs, CMS estimates combined payment impact for cardiac surgery -2 percent; for cardiology 0 percent; interventional radiology -4 percent; and for vascular surgery -3 percent.
  • Proposals for the geographic practice cost indices (GPCIs) include continuation of work floor GPCI at 1.000; continuation of Alaska work floor GPCI at 1.500 and frontier states at 1.000; and implementing the finalized the reorganization of several of the California localities, which would reduce 32 localities to 29. 
  • The Medicare Economic Index (MEI) cost share weights were finalized in CY 2023 to be rebased and revised, including a revision of the 2006-based MEI from collection and update of data with a new survey by the AMA, resulting in a 2017-based MEI cost shares. For 2024, CMS is delaying the implementation of this update due to the dramatic impact the data will have on MPFS payments.  
  • CMS addressed multiple misvalued and proposed value changes to specific new and established CPT® codes. Of interest is ultrasound guidance for vascular access (code 76937).
  • CMS proposed clarifications/revisions for evaluation and management (E/M) to include implementing separate payment for the office/outpatient (O/O) E/M visit complexity add-on payment (code G2211); and maintaining the current definition of “substantiative portion” for  split (or shared visits).
  • CMS proposed to classify additions to the Medicare Telehealth Services List as either permanent or provisional, thus replacing the Category 1-3 classification; and to revise the process for addition, removal or change in status to this list.
  • CMS proposed to continue payment for CPT® codes 98966-98968, extending the telehealth-related flexibilities provided to other audio-only services covered in the CAA 2023.
  • CMS proposed to extend the definition for allowance of direct supervision to be met with the use of real-time audio and video interactive telecommunications through December 31, 2024.
  • For teaching physicians, CMS proposed these providers have a virtual presence in all teaching settings, but only in clinical instances when the service is furnished virtually (3-way telehealth visit, with all parties in separate locations).

The complete MPFS proposed rule summary can be found on the GORE Coding Resource Center website under “Education – CMS Rules Updates”: https://gore.rccsclients.com/education/rules-updates/.